Regulatory

Subscribe to Regulatory via RSS

Current Texas Insurance Commissioner Cassie Brown announced this week that she will be retiring on February 2. Brown has led the Texas Department of Insurance (TDI) for the past four years, and her tenure with TDI has spanned many more. Before serving as commissioner, Brown was the commissioner of TDI’s…

Read More Texas Will Have a New Insurance Commissioner

On October 10, 2025, the Connecticut Department of Insurance (the Department) issued Bulletin SL-6 (the Bulletin) to restate the requirements generally applicable to surplus lines placements, and to advise that the diligent effort exception established by Public Act 25-87, effective October 1, 2025, only applies to surplus lines brokers when they procure insurance coverage through an unaffiliated wholesale broker. The Bulletin additionally supersedes and rescinds Connecticut Bulletins SL-3 and SL-5.Read More When Surplus Lines Brokers Are Off the Hook: Connecticut Department Issues Bulletin on New Diligent Effort Exception

On August 20, 2025, the Colorado Division of Insurance (Division) amended Regulation 10-1-1 to expand its existing limited applicability to insurers offering individual life insurance to apply to insurers offering private passenger auto and health benefit plans effective October 15, 2025. Evidence of compliance with the amended regulation must be made available to the Division upon request for private passenger auto and health benefit plan insurers beginning on July 1, 2026.Read More Colorado Division of Insurance Expands AI Governance and Framework Regulation to Private Passenger Auto and Health Benefit Plan Insurers

On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that escalating global conflicts are intensifying threats to the U.S. financial system. The letter highlights increased risk from destructive cyberattacks, sanctions evasion, and illicit activity involving virtual assets. NYDFS urges institutions to take immediate, proactive steps to strengthen operational resilience, ensure compliance, and protect the financial sector from geopolitical spillover.Read More NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

On June 13, Florida Gov. Ron DeSantis signed House Bill 1549 into law. Among other things, the bill has removed the “diligent effort” requirement applicable to surplus lines agents.Read More Florida Bill Eliminating the Surplus Lines Diligent Effort Requirement and a Discussion on Surplus Lines Regulation Trends

Delaware has recently enacted legislation concerning the registration of trade names or “doing business as” names (DBA). This new process mandates that DBAs be registered online through the OneStop application. The Delaware Department of Revenue (DOR) will oversee the statewide DBA registry.Read More To Re-Register Your DBA or Not: That Is the Question in Delaware as New Law’s Effective Date Gets Pushed

Join Locke Lord, InsurTechNY and InsurTech Hartford for their next InsurTech Legal Academy webinar series on common licensing issues that InsurTechs face when starting up or expanding their insurance-related activities. Expectations differ between the various states, as well as the NAIC, regarding what activities do and do not require insurance producer and surplus lines broker licensure (both on an individual and entity level). Moreover, even if an InsurTech is not making a final decision on whether to accept or deny a claim, it may “cross the line” into licensable activity as well. Zach and Moya will also touch on nuances in the reinsurance intermediary space as well, which differ substantially from insurance producer licensing standards in a number of states.
Read More Join Us for Our Next InsurTech Legal Academy Webinar: A Deep Dive Into Producer, Adjuster and Reinsurance Intermediary Licensing Regimes

On May 24, 2024, the Massachusetts Division of Insurance (the “Division”) issued Insurance Bulletin 2024-06, “inducements, rebates and affiliated entities” (the “Bulletin”). The Bulletin is addressed to “all licensed insurance companies and insurance producers.” The Division issued the Bulletin to “remind insurance companies, officers thereof, and insurance producers authorized to operate in Massachusetts” that Massachusetts law prohibits, as an unfair or deceptive act or practice in connection with the transaction of insurance business, insurance companies, officers, and producers from “paying, giving, or allowing to pay or give, directly or indirectly, ‘anything of value’ or ‘any valuable consideration’, not specified in the insurance contract, as an inducement to the purchase of insurance or a rebate of insurance premium.” The Bulletin further reminds insurance producers that Massachusetts law also prohibits any “special favor or advantage” to accrue to an such producer that is not specified in the policy. Unlawful rebates or inducements are not solely limited to “reductions on insurance premiums”, but rather such rebates or inducements “include payments, reductions or discounts, not specified in the insurance contract, that would bestow anything of value, valuable consideration, special favor or advantage on the insurance producer.”…
Read More Massachusetts Issues Insurance Bulletin Discussing Inducements, Rebates and Affiliated ‎Entities

On May 23, 2024, the New York Department of Financial Services (the “Department”) issued Insurance Circular Letter No. 3 (the “Letter”). The Letter is addressed to “all insurers authorized to write property/casualty insurance in New York State, the New York Property Insurance Underwriting Association [‘NYPIUA’], and rate service organizations.” The purpose of the Letter is to “encourage all insurers authorized to write property/casualty insurance in New York State (‘insurers’) to offer loss mitigation tools and services to insureds for free or a reduced fee…and to encourage insurers, the [NYPIUA], and rate service organizations…to file with the [Department] actuarially appropriate discounts for insureds for the installation of devices or systems that mitigate or prevent losses….” As a result in a rise in the InsurTech space, in 2021 the National Association of Insurance Commissioners (“NAIC”) updated the anti-rebating section of the NAIC Model Unfair Trade Practices Act (#880) (Section 4(I)) by excluding various value-added products or services that an insurer or producer may offer at no cost or a reduced fee from the definition of impermissible discrimination or rebates. Other states have also implemented such changes.
Read More New York Department of Financial Services Issues Guidance on Insurance Loss Mitigation ‎Tools and Services